In 2011, the U.S. Environmental Protection Agency (EPA) issued pioneering guidance on the Best Available Control Technology (BACT) analysis for the control of greenhouse gas (GHG) emissions. In that guidance, EPA acknowledged that carbon capture and sequestration (CCS) is “an expensive technology” that will typically be eliminated under the economic impacts analysis conducted under Step 4 of EPA top-down BACT determinations in air permitting proceedings. Yet, EPA also noted that “CCS may become less costly and warrant greater consideration in Step 4 of the BACT analysis in the future.” Has the future arrived?
A petition by Sierra Club to EPA’s Environmental Appeals Board (EAB) challenging a Prevention of Signifi cant Deterioration (PSD) GHG permit issued in Texas raised this key question for evaluating CCS on BACT cost-effectiveness grounds and was recently denied by the EAB. With GHG New Source Performance Standards (NSPS) for new and existing coal-fired power plants looming, the decision evaluating cost analyses for CCS has potentially important implications.
Originally published in EM Magazine, July 2014.
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